RA-07-261, Response to Alliance for a Clean Environment 12/22/2007 Letter Concerning for the Alliance for a Clean Environment Possible Construction of a Trash-to-Ethanol Plant Approximately One Mile from Limerick Nuclear Plant

Response to Alliance for a Clean Environment 12/22/2007 Letter Concerning for the Alliance for a Clean Environment Possible Construction of a Trash-to-Ethanol Plant Approximately One Mile from Limerick Nuclear Plant

ML080240393
Person / Time
Site:	Limerick
Issue date:	01/24/2008
From:	Barkley R S NRC Region 1
To:	Cuthbert L Alliance For A Clean Environment
Barkley R S
References
RA-07-261
Download: ML080240393 (3)

Text

January 24, 2008

Dr. Lewis Cuthbert The Alliance For A Clean Environment 1189 Foxview Road Pottstown, PA 19465

Dear Dr. Cuthbert:

I am responding to your letter and e-mail to me dated December 22, 2007, which detailed the concerns of the Alliance for a Clean Environment (ACE) regarding the possible construction of a trash-to-ethanol plant approximately one mile from the Limerick Nuclear Plant. In particular, you raised concerns regarding potential water shortages due to the water demands of such a facility, increased security demands on Exelon, and the potential for ethanol explosions, fires and spills on or near the Limerick property due to the facility's operations or the shipment of ethanol near the plant.

Based on my search of the Internet as well as a review of recent newspaper articles, I understand that this proposed facility is only a conceptual proposal at this time and the Limerick Township is currently evaluating rezoning the subject property for a range of possible industrial applications. While I cannot comment on the specifics of this conceptual proposal, the NRC does require licensees to assess the potential impacts of industrial facilities nearby nuclear plants, such as chemical plants, fossil fuel stations, natural gas lines, and even liquefied natural gas (LNG) terminals. Specifically, licensees are required by NRC regulations (10 CFR 50.71(e)) to maintain their Final Safety Analysis Report (FSAR) up to date. The FSAR includes the potential impacts to the safe operation of the facility of nearby industrial facilities, including railways. Changes that impact the FSAR must be evaluated against the criteria contained in NRC regulation 10 CFR 50.59. This regulation establishes the criteria that determine whether a change can be implemented by the licensee with or without prior NRC approval. The NRC performs inspections under its Reactor Oversight Process of licensee changes that impact the FSAR.

As the project is only a conceptual proposal lacking preliminary design specifics, Exelon is not required to perform such an evaluation at present. If this facility proceeds toward construction authorization, Exelon will be required to perform such an evaluation. Exelon will also need to evaluate whether such a facility would pose an additional security challenge to Limerick and L. Cuthbert 2 adjust its NRC approved Security Plan accordingly. Finally, the water usage issue you raised is a matter within the jurisdiction of the Commonwealth of Pennsylvania; the NRC would only become involved if the water diversion from Limerick impacted the facility's ability to operate going forward in compliance with federal and state licensees and permits. Please note that the facility does have a large spray pond onsite to provide both plants with an ultimate heat sink in the event the cooling tower system is lost; water from the river is not necessary for the safe shutdown of the Limerick reactors.

We appreciate your concerns in this matter and trust that we have been responsive.

Sincerely, /RA/ Richard S. Barkley, PE Technical Communications Assistant

L. Cuthbert 3 adjust its NRC approved Security Plan accordingly. Finally, the water usage issue you raised is a matter within the jurisdiction of the Commonwealth of Pennsylvania; the NRC would only become involved if the water diversion from Limerick impacted the facility's ability to operate going forward in compliance with federal and state licensees and permits. Please note that the facility does have a large spray pond onsite to provide both plants with an ultimate heat sink in the event the cooling tower system is lost; water from the river is not necessary for the safe shutdown of the Limerick reactors.

We appreciate your concerns in this matter and trust that we have been responsive.

Sincerely, /RA/ Richard S. Barkley, PE Technical Communications Assistant

Distribution

RBarkley, ORA MMcLaughlin, ORA HCherno ff, NRR PBamford, NRR PKrohn, DRP TSetzer, DRP

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